SMITH, Justice.
This proceeding was instituted by Grady J. Prentice, trading as the Prentice Poultry Plant, against the City of Richmond for the correction of an allegedly erroneous tax assessment made pursuant to § 10-85 of Chapter 10 of the Richmond City Code of 1937, as amended, which section imposes upon wholesale merchants a city revenue license tax based upon purchases during the preceding year, and contains the following exception, in paragraph (c):
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